MANSFIELD - In a civil suit filed in Medina County, a Medina man alleges the organizers of the annual Ink in the Clink tattoo and music festival owe him millions of dollars.

The suit, filed in Medina County Common Pleas Court on Oct. 26, 2017, alleges Rickey and Susan Fields, with a last known address on North Lexington-Springmill Road in Ontario, owe Michael Kaminsky of Medina millions of dollars. Kaminsky claims he loaned them money for the festival and was promised part of the festival proceeds through an oral contract.

Whiskey Warehouse, 1400 West Fourth St., Mansfield, is also named as a defendant in the case.

Attorney Timothy Weyls of Weyls Peters and Chuparkoff, an Independence-based law firm, filed the suit.

According to the suit, the Fields were tenants in a building owned by an affiliate of Kaminsky since around 2009 in Wadsworth and until recently operated a business there.

Rick Fields met with Kaminsky at his home in Medina and said he and Susan Fields needed financial assistance for Ink in the Clink, according to the suit.

Rick Fields told Kaminsky a major musical act was needed for each day of the three-day festival to promote the event and generate advance ticket sale revenue. He told Kaminsky the festival would be successful if major bands could be secured by paying them in advance, according to the suit.

Rick Fields told Kaminsky that Gene Simmons or his band, KISS, would be attending the festival and showed Kaminsky a contract he said was the event contract with Gene Simmons' management company, according to the suit.

Kaminsky entered into an oral contract with the Fields and had a partnership for the event around September 2016 "based on their relationship and other representations and assurances about the event," according to the suit.

"Defendant, Rick Fields, knowingly made false representations to Plaintiff (Kaminsky) to induce him to enter into the Contract and the partnership," Weyls writes in the suit.

Rick Fields told Kaminsky that along with the need to pay musical acts in advance, the partnership needed to pay for costs associated with the facility rental, permits and the cost of the stages and other equipment, according to the suit.

The Fields told Kaminsky he would be repaid any money he paid in advance to the partnership, and he would also receive one-half of the net profits from the festival, "since without Plaintiff's (Kaminsky's) funds, the event would not have been possible," according to the suit.

Kaminsky made numerous advance payments to the partnership from September 2016 through March 2017, according to the suit.

The 2017 Ink in the Clink festival took place July 14 to July 16 at the Ohio State Reformatory.

The festival included around 80 tattoo artists, numerous food trucks and other vendors and performances by more than 40 musical acts.

Neither Gene Simmons nor KISS was part of the 2017 festival, as Rick Fields had told Kaminsky before they entered the partnership, according to the suit.

According to the suit, around 48,000 tickets were sold for the festival, at an average ticket price of $55, resulting in more than $2.6 million in ticket sale revenue. Other revenue included advertising revenue around $850,000 from Monster Energy and Budweiser, alcohol revenue around $200,000 after the suppliers' costs, parking revenue around $50,000 and booth rental fees from tattoo artists around $200,000.

The gross revenue from the 2017 festival was more than $4.2 million, according to the suit.

The suit states the Ohio State Reformatory received around $7 per ticket sold, or about $335,000, paid directly by the ticket sale agent.

Other costs for permits, licenses, temporary bathroom facilities, shuttle service from the parking areas, security and rental expenses for equipment totaled around $130,000.

Rick Fields told Kaminsky the net profit from the festival was around $3.8 million, according to the suit, which he said was in the account for the event.

Kaminsky contributed at least $180,250 to the partnership, according to the suit. He paid around $125,000 by wire transfer directly to United Talent Agency for the musical acts.

The Fields told Kaminsky the advances not paid directly to third parties would only be used for the event and would be held in a separate account, according to the suit.

Kaminsky later learned the funds believed to have been advanced only for the event were paid to accounts for the Fields and Whiskey Warehouse, according to the suit.

Kaminsky paid around $28,250 by check or electronic funds transfer to the defendants in Medina and around $27,000 to an account in the name of Whiskey Warehouse. That account was supposed to be only for the event, according to the suit.

"Defendants used funds received from third parties (such as advertising money) in advance of the Event to pay for other Event expenses because Defendants did not have the money on their own to operate the Event," Weyls writes in the suit.

Kaminsky has not been repaid, and the Fields have not returned his phone calls or been at their businesses in Mansfield or Wadsworth during normal business hours, according to the suit.

"Plaintiff (Kaminsky) has made numerous demands for payment and for information relating to the Event, all of which Defendants (Rick and Susan Fields) have ignored," Weyls writes in the suit.

According to the suit, Rick and Susan Fields have stopped paying employees and vendors for Whiskey Warehouse, which appears to be closed.

The suit alleges Rick and Susan Fields have purchased new vehicles with some of the partnership funds, including a new extended cab pickup to pull a newly purchased recreational vehicle.

According to the suit, Rick and Susan Fields may have left or are planning to leave the state with the event proceeds. It claims they use numerous bank accounts with several financial institutions, plus numerous PayPal and Square accounts, and that they have converted a "substantial amount of revenue" from the event to Bitcoin, a virtual cryptocurrency operating on an open source peer-to-peer network with no middlemen or control agents.

"Due to its nature, Bitcoin may be difficult to control or track and it can easily be concealed by users intending to defraud others, such as Defendants have done in this case," Weyls writes in the suit.

Kaminsky is seeking in damages the $180,250 he loaned to the Fields; one-half of the net profits from the 2017 Ink in the Clink festival, believed to be around $1,809,875; and $12,537.36 he paid to unfreeze the event account because of tax liens, plus interest, attorney's fees and other costs.

Kaminsky is also seeking in damages an amount in excess of $25,000, to be determined at trial, on a fraud count; an amount in excess of $25,000, to be determined at trial, on a conversion of event monies count; and an amount in excess of $13,008, to be determined at trial, on a conversion of other monies account.

Kaminsky is also seeking to review the event's financial records and documents.

According to the suit, Rick Fields has a past criminal conviction for felony theft, for which he was incarcerated for five years in South Carolina.

Kaminsky's motion for default judgment is scheduled for a non-oral hearing at 8 a.m. Feb. 12. No appearance is necessary, according to court records.

A second civil suit filed in Medina County Common Pleas Court on Oct. 26, 2017, alleges Rickey and Susan Fields, who operate New Ink Tattoos at 232 High St. in Wadsworth, did not pay rent on the property for 18 months, totaling $9,000, or pay their utilities, totaling $4,162.38.

They entered into a five-year lease with the plaintiff, Wadsworth Properties South, on May 1, 2012, expiring on April 30, 2017. Monthly rent was set at $400 per month plus utilities.

The Fields vacated the premises and abandoned all property inside, according to the suit, which also says they damaged the leased space, requiring repairs.

Wadsworth Properties South is seeking damages in excess of $25,000, plus interest, attorney's fees and other costs.